Raj Madan is head of the firm’s global Tax Controversy and Litigation Group and Washington, D.C. Tax Group. He is a nationally recognized tax controversy lawyer with experience in resolving high-stakes and complex tax disputes.
Madan handles matters at all stages of IRS administrative practice, as well as federal district court and tax court litigation. Clients turn to him to advise on a wide range of complex tax issues, including transfer pricing, cross-border withholding tax, foreign tax credits, structured finance, life insurance, investment tax credits, and business purpose doctrine and partnership disputes.
Lawdragon Honors
| Honor | Year | Practice |
|---|---|---|
| The 2026 Lawdragon 500 Leading Global Tax Lawyers | 2026 | Tax, Controversy, Litigation |
| The 2026 Lawdragon 500 Leading Litigators in America | 2026 | Tax Litigation |
| The Inaugural Lawdragon 500 Leading Global Tax Lawyers | 2025 | Tax, Controversy, Litigation |
| The 2025 Lawdragon 500 Leading Litigators in America | 2025 | Tax Litigation |
| The 2024 Lawdragon 500 Leading Litigators in America | 2024 | Tax Litigation |
| Lawdragon 500 Leading Litigators in America | 2022 | Tax Litigation |
Madan’s ongoing cases include:
- Liberty Global, Inc. v. United States (U.S. District Court for the District of Colorado): Challenging regulations issued under Section 245A, a statute added as part of the Tax Cuts and Jobs Act of 2017. In April 2022, the court ruled that those regulations were invalid and unenforceable. This ongoing case implicates complex questions related to the IRS’ authority to issue regulations and apply them retroactively.
- Medtronic, Inc. v. Commissioner (U.S. Tax Court; U.S. Court of Appeals for the Eighth Circuit): One of the most significant transfer pricing disputes with the IRS, involving a second trial in the U.S. Tax Court after the Eighth Circuit’s review and remand. The Tax Court’s 2022 ruling adopted Medtronic’s transfer pricing methodology but made certain adjustments in favor of the IRS.
- SIH Partners, LLLP, Explorer Partner Corp., Tax Matters Partner v. Commissioner (U.S. Tax Court): Ongoing case on behalf of Susquehanna International Group, LLP involving the taxation of dividends paid on Swiss equities.
- BankUnited, Inc. v. United States (U.S. District Court for the S.D. Florida): A tax refund case of first impression concerning the application of the Treasury Regulations under Section 597 to the acquisition of a failed bank.
Madan’s recent cases include:
- Amazon.com, Inc. v. Commissioner (U.S. Tax Court; U.S. Court of Appeals for the Ninth Circuit): A 2017 victory in one of the largest transfer pricing cases in decades and the first involving e-commerce. In 2019, a unanimous panel in the Ninth Circuit affirmed the Tax Court’s decision.
- Starr International Company, Inc. v. United States (U.S. District Court for the District of Columbia; U.S. Court of Appeals for the D.C. Circuit): The case, dismissed in 2019, involved the first taxpayer attempt to challenge a U.S. competent authority decision to deny discretionary relief under a tax treaty.
- Lehman Brothers Holdings Inc. v. United States (U.S. District Court for the Southern District of New York; U.S. Court of Appeals for the Second Circuit): A 2015 trial court decision in the U.S. government’s favor in a case involving an interpretation of the U.S.-U.K. Tax Treaty. The case was settled in 2016 while pending appeal to the Second Circuit.